Gisela Römmelt 13/11/2016
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First part:
The German Renewable Energy Sources Act (German: Erneuerbare-EnergienGesetz
; EEG)
In the year 2000 the federal Ministry for Economic Affairs and Energy introduced the
German Renewable Energy Source Act to promote green energy to make the power
supply of Germany more environmentally sound and climate-friendly and to become
less dependent on the import of fossil fuels. This should be achieved by enabling
young technologies to enter the market with support provided by the state. In the
initial version of the act this was done by providing fixed feed-in tariffs for each kWh
produced. The technologies covered were wind, water, landfill and mine gas,
photovoltaic, biomass and geothermal energy. Beside that a purchase guarantee
was introduced and the renewable energies were given a priority feeding-in into the
grid. This enabled the technology for renewable energies to emerge from a niche.
After the accident of Fukushima in 2011 and the German decision to phase out
nuclear energy this act got even more important to support the German energy
transition and to reach the goal of a 35% share of renewable energies of the German
electricity consumption in 2020. In 2014 the act was revised to adapt to the new
conditions and requirements that appeared after 14 years of this support scheme.
Main reason for the adjustments was the cost increase because of the “EEG
surcharge” up to €22bn in 2013 (Lang M., Lang A. 2015). Through the use of
mandatory direct marketing with market premiums and the reduction of the feed-in
tariffs in each following year a cost reduction should be achieved. For example for
photovoltaic installations up to 1 MWp the remuneration declined from 16.50 ct/kWh
in 2012 to 12.15 ct/kWh in 2015 (JM ProjectInvest 2016). Beside that they introduced
quantity targets for the annual increases to better manage the expansion of the
renewable energies and started Pilot auctions to bring them closer to the
marketplace (BMWI 2016a). Since the start of the act the share of renewable
energies of the gross electricity consumption in Germany increased from 6.2% in the
year 2000 to 31.6% in 2015 (BMWI 2016b). The renewable energies developed
rapidly and do not represent a niche technology anymore. Therefore new
adjustments to the EEG are needed to fit the new requirements and forward the
market integration on a new level. Hence for 2017 the Federal Ministry of Economic
Affairs and Energy is working on a new edition of the German Renewable Energy
Sources Act. The main focus is on comprehensive introduction of the competitive
tendering for all renewable energies and determination of fixed expansion corridors.
Federal association of wind energy in Germany (Bundesverband WindEnergie)
The federal association of wind energy in Germany is one of the biggest association
for renewable energies in the world. It is promoting the sustainable and efficient
expanding of wind power in Germany. The vision is to have 100 percent renewable
power in Germany (BWE 2016a). To achieve that they work together with the
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decision-makers to ensure good basic conditions for wind energy in the German
market. That is why there is a special interest of the association for proposed
adjustments and changes to regulations concerning the wind power like the German
Renewable Energy Sources Act.
The proposed new edition of this act in 2017 has a strong influence on the wind
industry in Germany. In particular the changes concerning the introduction of
competitive bidding and the new quantitative targets proposed at a level of gross
instalment of 2,800 MW for the years till 2019 and 2,900 MW for 2020 for onshore
wind power calculated by a special formula. There is a high risk that the new act
strongly curb the expansion of wind energy by introducing stronger limits than
needed to ensure energy security and a good grid connection. Wind industry could
experience a downturn with less investments taking place. It would not only slow
down the energy transition in Germany but with this restrictions it will not be possible
to comply with the climate goals set in the Paris agreement 2015. There are no
reasonable grounds to limit the expansion in some grid areas. The federal
association of wind energy wants to ensure that even after the EEG reform of 2017
the wind energy in Germany is not restricted in its growth opportunities, that it stays
attractive for future investments and contributes to the success of the energy
transition. The aim of this paper is to point out the need for higher instalment rates of
onshore wind power plant and set the basis for the renegotiation of the “deployment
corridors” for the next years and the used formula.
Federal Ministry for Economic Affairs and Energy
The Federal Ministry for Economic Affairs and Energy as part of the government is
not only responsible for strengthening the German market and ensure a sustainable
progress but also for reforming the energy system and promoting the German energy
transition by designing the needed legal regulations and requirements. So firstly it is
the important decision maker for the named issue as it proposes the changes for the
EEG but beside that it is also the ministry in charge for concerns of industries
concerning their business, which also relates to the issue. It is one out of fourteen
ministries having the executive power in Germany. Depending on their decisions,
interests and agenda settings the budget of the ministry is spend. For 2017 expenses
of € 2.4 Mio. are planned for the sector of energy and sustainability (BMWI 2016c).
This is represents one third of the overall budget of the ministry for 2017.
Gisela Römmelt 13/11/2016
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Second part
Written comment on the proposed EEG 2017 by the federal
association of wind energy in Germany
Commitment of the German Government to the climate goals of the Paris
Agreement 2015
The German Government has ratified the Paris agreement in September 2016 and
therefore committed itself to the goals of the agreement. The key element is to limit
the increase of global temperature to 1.5°C by a drastic reduction of global emissions
(European Commission 2016). For achieving this experts agree on the need to have
zero emissions as early as in the year 2040 (Quaschning V. 2016). Already before
this agreement the German government approved the goal to have 40 – 45 percent
less emissions in 2020 compared to the numbers of 1990. Unfortunately until now
only a 27 percent reduction is achieved. To still fulfil the goal a threefold increase of
the activities is needed (Kersting S. 2016). Beside that it is controversial if this goal is
still ambitious enough concerning the Paris agreement. Therefore this 45 percent
should not be seen as a maximum but rather as a minimum. It is evident that to
achieve the goals for 2040 even with the use of the CCS technique, which is still
controversial especially concerning the economic efficiency, the use of fossil fuels as
the main primary energy sources has to be reduced to nearly zero. To substitute this
sources more renewable energies are needed to ensure a stable energy supply.
Currently the share of renewable energies on the primary energy supply is only 12.6
percent. That shows clearly that the instalment of renewable energies needs to be
accelerated to achieve a decarbonised energy supply in 2040. For using renewable
energies in a high share it is important to know the different potentials of each source
of renewable energy for the German energy supply to make the right decisions. The
conditions for energy from water power plants is very small in Germany and already
developed. Secondly in nearly all models made by institutions like Fraunhofer for the
future energy systems in Germany the geothermal sector is not taken into account as
it is not financial feasible because of the high investment costs (Henning H. et. al.
2013). Furthermore the potential of solar thermal energy especially for the heat
sector in Germany is very limited to some regions with high solar radiation (FfE
2016). Therefore the overall potential is very small as well. Concerning primary
energy from biomass the potential of using organic waste material is already
exhausted. Wood as a source for energy is already used for two-third therefore the
biggest potential is with the cultivated biomass (FNR 2016). However the estimations
about this potential differ between less than 200 TWh (Fraunhofer IWES 2015, p.1)
and up to 500TWh (FNR 2016). These numbers are always related to the technical
potential of the source. Problematic is here the usage competition for the agricultural
area as some of the calculations were based on assumptions about a declining need
for area of the agricultural industry. Therefore it is not clear if the whole potential can
Gisela Römmelt 13/11/2016
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be exploited. The remaining energy demand has to be covered by energy from solar
and wind power plants, which have the biggest potential in Germany and are the
most cost efficient sources. In the following section the needed capacity of wind will
be calculated for two different scenarios concerning the decarbonisation of the heat,
transport and electricity sector for the year 2040. These results will be confronted
with the planned corridors for renewable energies of the EEG 2017.
The importance of a coupling of the energy sectors and the resulting energy
capacity
It is undisputed that for a successful energy transition and achievement of the climate
goals not only the electricity sector needs to be decarbonised but to the same extend
the heat and transportation sector. The decarbonisation of these sectors will lead to
an increasing demand for electricity because the potential for directly generating heat
from solar thermal energy and the geothermal sector is limited as well as the
production of bio fuels with the help of biomass compared to the high demand
(Quaschning V. 2016, p. 13). Therefore the potential of wind and solar energy has to
be made available for the other sectors with the help of for example the power to gas
or heat technology. To estimate the total electricity demand for the future each sector
will be looked at separately. The following numbers are based on two studies. The
Fraunhofer IWES institute is calculating with more conservative numbers with the
ambition to reduce greenhouse gas emission by 80 percent until 2050, whereas the
University of Applied Science in Berlin is following a very ambitious scenario with a
reduction of 100 percent until 2040.
The heat sector
With 4840 PJ the heat sector represented 56 percent of the final energy demand in
Germany in the year 2014 (BMWI 2016d). A small part of this demand can be
covered by biomass, solar thermal power plants and geothermal heat in the future.
Deducting this share and taking into account an increase in efficiency over 40
percent in the space heating and of approximately 30 percent for industrial processes
the remaining demand for electricity in the heat sector for the year 2040 will be round
about 400 TWh in the ambitious scenario (Quaschning V. 2016, p.19) and up to 230
TWh for the conservative scenario (Fraunhofer IWES 2015, p. 32). This includes not
only the space heating and warm water but also process heat for the industry. The
biggest part will be covered by electric heat pumps as the most efficient technology.
Beside that the methane produced in the Power-to-Gas process is used as a
substitute for the natural gas.
The transportation sector
With 2630 PJ the transportation sector represented 30 percent of the final energy
demand in Germany in the year 2014 (BMWI 2016d). In general it can be said that a
complete decarbonisation of the transportation sector is probably not possible within
23 years as over 90 percent of the energy needed is still covered by fossil fuels.
Nevertheless it is possible to have enormous reductions of the emissions caused by
Gisela Römmelt 13/11/2016
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this sector. Beside the increase of efficiency and a promotion of public transport the
shift to electro mobility plays an important role. The complete substitution of the fossil
fuels by biofuels is impossible as there is not enough agricultural area available. For
a really ambitious scenario with a radical decarbonisation of the transportation sector
337 TWh of electricity are calculated (Quaschning V. 2016, p. 25). More conservative
studies are suggesting that an electricity demand of up to 170 TWh is needed
(Fraunhofer IWES 2015, p.30).
Electricity demand in 2040
The goal for the conventional electricity demand is a reduction of 25 percent until
2050 in comparison to the numbers of 2008. The remaining electricity demand for
2040 would be a little bit higher than 400 TWh. In the study from the University of
Applied Science in Berlin this number is said to be 500 TWh in the year 2040 taking
into account high conversion losses (Quaschning V. 2016, p. 28). Summing this up,
following the ambitious scenario with a 100 percent reduction of greenhouse gas
emissions this would result in an electricity demand of 1240 TWh. The more
conservative scenario results in a total demand of around 800 TWh (Fraunhofer
IWES 2015, p. 1).
It has to be said that the above presented numbers can only present estimates about
the final electricity demand. Especially factors like the population and economic
growth as well as the development of different technologies are hard to predict and
have a influence on the final demand. Different assumptions about these factors
influence the outcomes. Nevertheless it can be assumed that the current electricity
production of 646 TWh in 2015 (DESTATIS 2016) has to be increased by at least 30
percent and covered completely by renewable energies to achieve a notable
reduction of emissions. Depending on the scenario and the assumptions made,
probably even an increase of more than 90 percent is necessary for a complete
decarbonisation.
Table 1: Development of the renewable electricity production until 2040 considering the
proposals for the EEG 2017
Proposed
annual
installed
capacity in GW
Installed
capacity in
2040 in GW
Full load
hours h/a
Renewable
electricity
production 2040 in
TWh
Onshore 2,8 (gross) 56 2200 123
Offshore1)
0,85 (net) 24 4200 100
PV 2,5 (gross) 50 950 48
Biomass 0,1 (gross) 3 5500 17
Water power 0,05 (net) 7 3800 27
Sum 315
Source: own calculations with numbers from the EEG 2017, AfEE (2016a) and Quaschning
V. (2016).
Gross: including repowering
1)
offshore goals: 6.5 GW till 2020 and 15 GW till 2030
Gisela Römmelt 13/11/2016
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Calculating the electricity production from renewable energies for the year 2040 by
taking the proposed “deployment corridors” from the EEG 2017 the result of 315 TWh
(see table 1) would not even cover the current demand for electricity with around 550
TWh (BDEW 2016) and by far not the demand needed for a decarbonisation in the
heat and transportation sector in the near future.
This demonstrates clearly that for complying with the climate goals from the Paris
Agreement the targets for the “deployment corridors” for the next years have to be
set higher instead of lowering them to ensure a stable and constantly high instalment
of the renewable energies in Germany. Otherwise the increased need for electricity in
the future can not be covered sufficiently. Roughly an annual instalment of 4 GW is
needed to at least cover the demand calculated in the conservative scenario
(Fraunhofer IWES 2015, p. 42). For the more ambitious scenario the proposed new
instalment of onshore wind power plants is 6.3 GW (Quaschning V. 2016, p.34),
which may be too high to be realized. In 2016 the gross instalment for onshore wind
power will be between 4 – 4.4 GW and our experts expect a gross instalment of 4.3 -
4.9 GW for the year 2017 for onshore wind power (Zelinger M. 2016). So actually the
above presented number of 4 GW is realistic if policy is supporting this development.
Taking a realistic scenario where 2 percent of the area of Germany can be used for
onshore wind power production this would result in approximately 200 GW installable
capacity for Germany (Quaschning V. 2016, p. 31).
Challenge of grid integration
For a successful energy transition the grid modification and extension is crucial. The
current delays must not be a hindrance for the further instalment of the renewable
energies. Especially the optimization and strengthening of the grid are aspects that
can be realized on a short-term to increase flexibility (BWE 2014, p. 8) hence there
should be a strong focus on that in the next years. In the following there will be
examples for measures that can be implemented on a short-term for increasing the
grid strengthening and beside that approaches will be pointed out that increase
efficiency and reduce the overall need for grid extension.
It is important that grid operators are obliged to implement the NOVA principle, which
is about grid optimization before strengthening and extension, in a timely manner.
For the better integration of wind power especially measures like temperature
monitoring and high temperature wires can be used for this as they increase the
transmission performance enormously. Both measures can be used in the
transmission and distribution grid. Because the NOVA principle contributes to cost
efficiency and a higher acceptance it will accelerate the grid adjustment. To further
decrease the need for grid extension feed-in management should be taken into
account. One possibility for that is the relinquishment of feeding in the last kilowatt. A
reduction of the feed-in peaks by 31 percent, which would only lead to a loss of
annual output by 2 percent could reduce the needed transmission performance by 30
Gisela Römmelt 13/11/2016
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percent (BWE 2014, p. 12). This feed-in management should be remunerated in
terms of a grid service for operators. Another aspect that is reducing the actual
needed grid capacity is the use of a simultaneity factor of wind and photovoltaic
smaller than one, which should be calculated specifically for different regions (BWE
2014, p. 14). To further expedite the needed expansion the use of so called “feed-in
grids” is very useful in areas where the capacity of renewable energies already is
higher than the actual load. The advantages of those grids are the simple grid
structure with a consistent use of 110kV (BTU 2013, p. 34).
Another important point is to make the power supply from conventional plants more
flexible by reducing the Must Run basis. Currently the must run capacity is hindering
the renewables to fully feed in their electricity. In case of excess capacity it happens
that in most of the times renewable production will be switched off instead of
regulating conventional power plants (Greenpeace 2016). To reduce the needed
must run capacity of conventional power plants renewable energies have to be used
for system relevant services. Especially biomass but also wind power plants are able
to deliver these services. Already now modern wind power plants can contribute to
frequency and voltage stability as they are very suitable for flexible output reduction
and also for the provision of reactive power (Khalil Al-Awaad A. 2009, p.80). To fully
enable them to do so the regulation concerning the balancing markets have to be
adapted as fast as possible (AEE 2016b). Therefore especially the auction
mechanisms for balancing power must become more flexible by having shorter
tendering time periods and unsymmetrical tendering for the three balancing phases
(BWE 2014, p. 27). Furthermore the usage of storage systems will decrease the
needed must run capacity. This will decrease the excess capacity in the grid,
stabilize the grid furthermore and reduce the need for limiting renewable energies in
their outputs. Last but not least the promotion of the energy sector coupling will help
to use excess capacity for heat or the transport instead of switching off renewable
energy power plants. The proposals made on that by the federal association of wind
energy can be found in the research paper “Umschalten statt Abschalten”.
These above presented aspects are only a few examples that demonstrate the
efficiency potentials and possible short term measures in the current electricity grid.
Grid operators as well as scientist are confirming these existing efficiency potentials
(BWE 2016b). Therefore it is not comprehensible why there should be a special
restriction for the new instalment of wind power plants in some regions because of
grid instability.
Financial aspects
Referring to the aim of the government to reach cost efficiency for the renewable
energies the onshore wind energy as the most cost-effective renewable energy
source is important and should therefore not be restricted. Although the onshore wind
energy represents nearly half of the generated electricity by renewable energies its
share on the EEG allocation is smaller than 20 percent (BWE 2016c). A high share of
onshore wind on the total renewable energies will therefore help to decrease costs
Gisela Römmelt 13/11/2016
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for the EEG allocation (DIHK 2016, p. 19). To achieve the economically most efficient
result there should be no preference for wind poor regions as this will lead to higher
costs. An equal framework for all regions should be set up. As already pointed out in
the section above with the help of efficiency measures for the grid there is no need to
restrict some regions in the north on there instalment of wind power plants as it is
done in the current proposal of the EEG 2017.
Importance of the wind energy industry for Germany
The wind industry is the most important employer in the renewable energy sector
with a share of 42 percent (BWE 2016d). 2014 the employment increased by 8
percent to over 150,000 employees (BWE 2016e, p.4). Beside that the industry
invested € 9.7 billion in the year 2015 and therefore represents the renewable energy
sector with the highest investments as well (Strom-report 2016). During the last years
the wind energy sector has developed to an important industry for Germany what
makes clear that the initial support was a success. Meanwhile the tax revenues
exceed the state support (ZWS 2013). In order for Germany to stay an attractive
location for the wind energy industry there has to be investment certainty for the
companies. In general it can be said that the amount of amendments made to the
EEG before are not giving the needed certainty for planning. Now with the new
design finally there are some clarifications especially about the tendering process but
one point where there are still open questions is the tendering quantity for onshore
wind power. Using the proposed formula to calculate the amount of installed capacity
new for every single year (BMWI 2016e) involves too many uncertainties for
investors. Beside that the results from this formula could be less expedient than
expected. That is because the formula is based on the gross electricity consumption
in the year 2025. As previously mentioned there are a lot of uncertainties about its
development. Parameters like the coupling of energy sectors, economic development
or digitalization of the economy will influence the actual value. Secondly for
calculating the generated power by already existing plants for the year 2025
assumptions have to be made about how many of the now existing plants have been
shut down by than (BMWI 2016e). The formula can not represent these two points in
an appropriate way. Another critical point is the calculation of the gross instalment
instead of the net instalment and the use of this calculated value for the actual
tendering capacity. Taking into account the proportion of already accepted bids that
are not going to be realized (around 10 percent) there is a high risk in not realizing
the initial calculated number and finally have less installed capacity than needed.
Therefore the federal association of wind energy in Germany is advising to have fixed
targets in terms of net instalment for the next years that represent the actual need for
onshore wind energy instead of using a formula. This will give the industry the
needed certainty for planning and investments as well as promote innovation and
help to achieve planned emission reduction in the given time frame.
Gisela Römmelt 13/11/2016
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Final statement
Concluding, the federal association of wind energy in Germany demands consistent
development of onshore wind energy. The “deployment corridor” for onshore wind
energy has to be set at least at the level of the EEG 2014 with a yearly net instalment
of 2.500 MW as this is completely acceptable with the grid stability and absolutely
necessary for achieving the set targets. However to comply with the climate goals of
Paris and to promote the energy sector coupling there is the strong recommendation
to have at least a yearly gross instalment of 4.000 MW, which is complying very well
with the forecasts from the industry for 2016 and 2017. The second demand on the
federal Ministry for Economic Affairs and Energy is the use of fixed net instalment
targets for at least the next three years instead of calculating annual varying volumes
with the presented formula. This especially is important for minimizing the
uncertainties for investors in this business. The government should promote the
transition of the energy system as an important factor for the economy, innovation
and the export sector and must not restrict the onshore wind power as its most
important and efficient performer. With a stricter limitation on the instalment capacity
the EEG 2017 will thwart the achievement of the national and international goals on
the climate protection.
Gisela Römmelt 13/11/2016
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